From: Kyle Degr·uttola [mailto:kyle clc~Qiuttola'Ci:qlic.corn] 

Sent: Wednesday, August 05, 2015 3:3 L PM 

To: Ta!k to DOL 

Subject: Proposed fiduciary Co11flict of !11terest Rule 

Dear Mr. Perez and Members of Congress: 

In regard to the proposed Fiduciary Conflict of Interest Ku le, I agree with the intei1tion of this rule. 

It does seem to increase the fiduciarv umbrella beyond 1Nhat would allow sUl'neone to teach students, friends, and 

family about retirement solutions. When revievving these solutions across !AS GA1\P to US GAAP from a reporting 

standard and how these 1·etirement solutions work, I shouldn't retain any fiduciary liability. I am simply a professor and 

someone that lries to help educate others in regard to my JreJs of expertise. 1-'\lso, limiting JCcess to variable annuities 

for lifetime income pu1·poses could have sever,, I significant negative effects 1ivhen considering the economic and legal 

reverberations that this could cause. Having positive correlation with finJllCial products that are tied to the productivity 

of mankind and our advancement in general aligns all of our inl1:?rests ancl produces synergies beyond 1Nhat someone 

pc:rsonally will be able to. This is often clue to irrational beh;:iviors of average people who will develop concentrated risky 

positions or misguiclecl positions which will not allow them to rneet their retirement and .independence goals. IRA 

owners and small businesses with fewer than 100_participanls should be able to have professionally m<Jnaged options 

structured by actuaries, m<1thematicians, a:1cl portfolio mi.lnJgcrs so they can clecrezise their r·isk and have the ability to 

obt<iin income For lifE' from double A or better proviclcr·s. Demogr-aphics suggest we a1-e going to experience a retirement 

funding crisis by the vear 2050. We as 1'.\mcricans need more information zrnd opportunity to save for retirement, not 

less, which is an uninte11cled co11sequc'r1ce of this rule. 

I feel JS though this bill could inc1ppropri<.1tely expand the scope of fiduci<ll"Y liability simply by rne explaining the benefits 

of health arid 1Nelfi.11·c plans. These <J1·e comrnon sense solutions that the government can provide information on as well. 

This is going to inuez1se llie burden on tile government to provide For cill the nee els of our citizens as they will not be 

informed ilS to how to plan for their f<rniilics' futures. Providing information on an IRA rollover or 401k rol'lover should 

not create a fiduciary responsibility by the provider. l11forr11ation ;:ibout this is provided on government websites already 

and simply directing someone to this inforrnation or providing said intelligence to someone should not create a fiduciary 

responsibility. Companies thJt perform risk sharing services by providing <rnnuities should be aided in doing so not 

restricted frorn provicli11rs this crucially importa11L /\111erica11 service. 

I agree with the in·tentions of this, however, I think thJt this will result in limiting individuals' ability to obtain 

informJtion am! solutions to thei1· retirement and hcc1lthcare needs. Plecise reconsider the areas I outlined. 

Advocacy 

Yours very truly, 

Professor l<yle Victor DeGruttola, MBA, CPA 

Best regards. 

Kyle DeGruttola, MBA-TECH, CPA 

Staff Accountant 

Finance Department 

Tel (212) 919-3553 

7 Hanover Square. H4D New York. NY 10004 

Kyle 9egruttola@ol1c com 

The Guardian Life Insurance Com pan)' of 

A mcrica